Yates v. Aiken

Background

A man convicted of robbery and murder during a 1981 country-store robbery was sentenced to death after a jury was told that malice could be presumed from the use of a deadly weapon. His conviction was affirmed on direct appeal in 1982. Later, the South Carolina Supreme Court held in a different case that that kind of instruction was erroneous, and the prisoner sought post-conviction relief arguing the instruction violated federal due process as explained in earlier Supreme Court decisions including Sandstrom and, later, Francis.

Reasoning

This Court explained that the remand it ordered was meant to require the state court to consider whether Francis and the older decision in Sandstrom meant the conviction could not stand. The Court concluded that Francis did not announce a wholly new rule but applied the existing Sandstrom principle prohibiting jury instructions that relieve the State of proving every element beyond a reasonable doubt. Because Francis followed settled federal law, the state court could not refuse federal relief simply by calling the rule “new.” The Supreme Court reversed the South Carolina decision and said the state must give the relief federal law requires.

Real world impact

Defendants convicted under jury instructions that implied intent from a weapon, especially in capital cases, can press federal collateral challenges based on Sandstrom and Francis. State courts cannot decline to apply those federal rules in post-conviction proceedings where the federal law requires relief. The case was sent back to the state court for further proceedings consistent with this opinion.

Dissents or concurrances

A dissenting justice argued Elmore and Francis should be applied retroactively because burden-shifting instructions seriously undermine the jury’s truth-finding role and did not represent a major change from Sandstrom.